2008-04-15_REVISION - M1980244 ‎(308)‎

• Permit No: M1980244
• IBM Index Class Name: REVISION
• Doc Date: 4/15/2008
• Doc Name: VOL VII APP 12 Appendix G Engineering Evaluation
• From: CC & V
• To: DRMS
• Type & Sequence: AM9
• Media Type: D
• Archive: No

•
•
•
3.0 SPECIFIC DEVIATIONS AND RATIONALE FOR THE CC&V FACILITY
3.1 Secondary Containment Structures
Crusher Shed secondary containment structures (i.e. steel grated pallets on a concrete floor) are not
large enough to hold the volume of the largest tank; however, the tanks containing grease are not likely to
spill outside of the pallets or the concrete shed floor due to the highly viscous nature of the grease
involved. Therefore, it is the opinion of the certifying. engineer that the Crusher Oil Shed does provide
"equivalent environmental protection." I
The 1200 gallon diesel tank mounted on the generator at the ADR does not have secondary containment
as the other generators have. Spills from the 1200 gallon unit can be partially contained by the
surrounding soil and rock surface. Jersey barricades do provide collision protection and a limited amount
of secondary containment for the smaller generator. Downgradient from the generator site are
stormwater controls (BMP's) that provide a measure of secondary containment that would prevent spills
of diesel from the 1200 gallon generator from moving offsite. Therefore, it is the opinion of the certifying
engineer that site conditions surrounding the smaller generator do provide "equivalent environmental
protection."
3.2 Exact Location of All Tanks and Containers Plotted on Site Map
The CC&V mine site is a large operation that has affected several thousand acres of land over its
operational history. Figures 3-6 depicts the location of containers and tanks covered by this ERP/SPCC
plan. Some locations are general and not exact, because the tank locations were not surveyed iri;
instead best field judgement was used to ascertain location, based on landmarks and roads. This does
not significantly impair the ERP/SPCC's ability to provide equivalent environmental protection in the
opinion of the certifying engineer.
i
3.3 Flow Path in the Event of a Spill Shown on :Site Map
Flat areas around certain structures make it difficult to decide how to depict flow paths on the site
diagrams in the event of a spill. The likelihood of a major spill in the vicinity of most structures onsite
escaping to a waterway is very remote, so that an argument can be made that not having the flow path
specifically designated on the map does not lessen the SPCC's ability to provide equivalent
environmental protection. Indeed downgradient from almost every containment structure is a stormwater
control feature such as a sediment basin or silt trap that would contain a spill to the land surface.
4.0 OVERALL EVALUATION OF SPILL POTENTIAL AT THE CC&V FACILITY
By far the greatest risk of spills would be the rupture or vandalism of one of the -large 100,000 gallon
diesel tanks at the Tank Farm or the rupture of one of the ADR Plant process chemical tanks. CC&V has
security measures in-place as discussed in the text of this ERP/SPCC plan which make it a highly unlikely
occurrence. Spillage of: (1) bulk oils or diesel fuel at the Tank Farm; (2) diesel fuel or hydraulic oil from
mobile equipment; (3) and process chemicals would likely be minimal (<50 gallons), due to the handling
procedures in-place and the various redundant containment structures and storm water controls onsite
In general, secondary containments are adequate and management is committed to rapid clean-up so
that any impact on the environment from spilled oil or environmentally sensitive materials should be
insignificant. Therefore, the overall potential environmental impact from CC&V spills is low.
Engineering Evaluation September 25, 2006
EMS: AGANA/CCV Page 2 of 2 Doc. # E-006
S:\4010-00055 CC & V 112(d) Permit Application\ERP, SPCC, FMP\APP-I-EngEval-5-06.doc
Printed Copies are Uncontrolled Revision 03